How does fair lending impact commercial loans, which is not “consumer protection” controlled?
For a home improvement loan, is the Purpose = Home Equity?
Is my bank exempt from the anti-steering requirements (i.e. giving the applicant 3 other loan options) in the LO Comp rules of 1026.36?
Can a fair lending enforcement action occur when no specific victims are identified?
Will Loan Production Offices help in fair lending if we decide to close branches?
When do we disclose Property Value instead of Sales Price?
Which regulator issues the most enforcement actions?
The CFPB hasn’t been active in fair lending other than mortgages, correct, does this present any challenges?
Our Executive VP earns a substantial annual bonus. He doesn’t really do any real estate lending, but he certainly talks with many bank customers (often on the golf course) about how the bank can provide various loan solutions, including home loans. Up to this point, he has kept his NMLS ID # and registration current “to CYA”. I’m concerned his bonus may be non-compliant with Loan Originator Compensation requirements. Should I be worried?
We have a loan that we are working on that is a purchase of a second home. The borrowers are son and daughter in law and mom. Son and daughter in law live in Michigan, mom lives in Florida.
* How do we get the closing papers signed and what should they be dated?
* Do we send two closing packages, one to each and then combine them, or send one closing package and have the son and daughter in law forward to mom?
* Can they date the documents before the closing?